What Data Do We Collect From You?

Personal information

You may give us information about you by filling in forms on our site or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register to use our site, subscribe to our services, place an order, transact on our sites or report a problem with our site. The information you give us may include your name, address, e-mail address and phone number, financial and credit information. Also, you may give us information relating to beneficiaries, shareholders, trustees and directors to enable us to deliver our services. The information you give us may include their name, address, e-mail address and phone number, financial and credit information.

If we have personal information from you, or information that is publicly available from other sources, we may use it in combination with the information that Sticpay has collected online. We can use this information to better tailor and personalize our service and marketing communications with you, both online and offline. The personal information you provide online is held by Sticpay to maintain your account or to process your application for a new product or service.

Non-personal information

When you visit our site, we collect technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform. This information helps us provide an online experience that matches your device.

When you browse our site, Sticpay and the companies we work with, use cookies and/or pixel tags to collect information and store your online preferences. It is important to note that cookies and pixel tags do not capture any information that can personally identify you. The information they gather helps us improve your online experience and may include: the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products you viewed or searched for; page response times, download errors and length of visits to certain pages.

We may also receive information about you if you use any other websites we operate or other services we provide. This data may be shared internally and combined with data collected on this site. We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them. Where this is the case, we will ensure this will be in full compliance of the Regulation.

How Do We Use The Information We Collect?

For our operation as a business and to provide banking and financial services including:

• To assess if you are suitable to work with/for us and subsequently process applications and transactions;
• To operate bank accounts, issue e-Money, make payments, to comply with obligations to our card partner and let you use all these services and to allow you to participate in interactive features of our service when you choose to do so;
• To ensure our websites, content and services are as effective and relevant as possible and give you the best experience they can;
• In case we need to check we have carried out your instructions correctly or to resolve queries or issues;
• To administer our business, including troubleshooting, data analysis, testing, research, statistical and survey purposes and to keep our business, websites, bank accounts and our systems safe and secure;
• To ensure that we comply with the law and regulations, for regulatory purposes generally as well as to help detect or prevent fraud or other crimes, and for tax, legal, reporting and auditing obligations;

To carry out our obligations arising from any contracts entered into between you and us:

• We process your information for the purposes set out above on the following grounds: where it is necessary for the adequate performance of contracts with you and to take steps requested by you prior to you entering into contracts with us.

To operate our business and to provide information about you to partners and businesses that integrate to us through APIs that you choose to integrate with:

• We process your information for the purposes set out above on the following grounds: your consent to do so where you choose to share your information with our partners and any other third parties and where it is necessary for the adequate performance of contracts with you and to take steps requested by you prior to you entering into contracts with us where our partners share it with us and being as efficient as we can about complying with legal duties, obligations and regulations that apply to us and keeping our records up to date.

To provide information, products and services that are requested from us, or other products and services that we or our business partners offer or to provide and to notify you about changes to our services:

• We process your information for the purposes set out above on the following grounds: to provide you with relevant product and services offers on our site and in other advertising, that may be of interest to you or that you have expressed an interest in hearing about, and where it is necessary to comply with legal duties, obligations and regulations that apply to us and keeping our records up to date.

Who Do We Share Your Information With?

With our affiliates to ensure we can do the things set out above in the section “How do we use your information?”;

With business partners, suppliers and subcontractors, with companies, organisations or individuals outside Sticpay for the performance of any contract we enter into with them or you or for the uses set out in the section “How do we use your information?”;

If we are under a duty to disclose or share your information in order to comply with any legal obligation, or in order to enforce or apply any agreement with you or our suppliers, to protect the rights, property or safety of Sticpay, our customers or others. This includes:

• Exchanging information with the Financial Services Compensation Scheme and with other companies and organisations for the purposes of fraud protection and credit risk reduction
• With tax authorities;
• With the police and other law enforcement bodies;
• With Labuan Financial Services Authority;

We may also share aggregated information (information about our users that we combine together so that it no longer identifies or references an individual) and non-personally identifiable information for industry and market analysis, demographic profiling, marketing and advertising and other business purposes;

Where Do We Store And Process Your Information?

We process your information and store it via our hosting provider, AWS (Amazon Web Services). Our server / platform environment is highly secure and there is very limited personnel access. Any information will be encrypted “at rest” (in other words, on being stored).

We try to ensure that we do not send your information outside the Labuan, Malaysia. However, this is not possible in all cases. If you are outside the Labuan, Malaysia and make payments or send messages, or you are in the Labuan, Malaysia and make payments outside the Labuan, Malaysia, we may process payments through other institutions and payment systems. They may have to process and store information about you in connection with their own regulations; please note that the standards to which they adhere may not be as stringent as those in the Labuan, Malaysia.

Unfortunately, the transmission of your information via the Internet can never be 100% secure. Although we will do our best to protect your information, we cannot guarantee the security of information about you transmitted to us and so any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.

Managing your information

You have the ability to control how your non-personal information is collected and used online.

You can control whether to accept cookies or not. If you decide to not accept cookies, some features and services on our site may not work properly because we may not be able to recognize and associate you with your Sticpay account(s). In addition, the offers we provide when you visit us may not be as relevant to you or tailored to your interests. If you would prefer not to accept cookies, you can change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it Set your browser to automatically not accept any cookies targeted.

Your right of accessing information about yourself can be exercised by emailing Sticpay at compliance_labuan@sticpay.com. Generally, we will store your information for five years but in certain circumstances, including through regulatory requirements, we may have to store this for a longer period. You may request that we delete your information or limit our use of your information and we will do so but:

• only if we do not need to retain it for any of the matters set out in the section “How do we use your information?” above;
• your information may be impossible to permanently delete and where this is not possible we will put that information beyond reasonable use;
• your information which you have shared with others (e.g. on our websites) may remain publicly available;
• please note that your information which you have transmitted to others, e.g. Marketplace partners, will be subject to their privacy policies.